---
title: "ESPR unsold goods disclosure tracker"
canonical_url: "https://www.sorena.io/artifacts/eu/ecodesign-for-sustainable-products-regulation/unsold-goods-disclosure-tracker"
source_url: "https://www.sorena.io/artifacts/eu/ecodesign-for-sustainable-products-regulation/unsold-goods-disclosure-tracker"
author: "Sorena AI"
description: "Track ESPR unsold consumer product disclosure fields, website publication evidence, destruction-ban status, owners, and unresolved source gaps."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "ESPR unsold goods disclosure tracker"
  - "unsold consumer products"
  - "Article 24 disclosure"
  - "Article 25 destruction ban"
  - "Annex VII textiles footwear"
  - "discarded products evidence"
  - "ESPR"
  - "Annex VII"
  - "textiles"
  - "footwear"
---
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---

# ESPR unsold goods disclosure tracker

Track ESPR unsold consumer product disclosure fields, website publication evidence, destruction-ban status, owners, and unresolved source gaps.

*ESPR* *Tracker* *EU*

## ESPR unsold goods disclosure tracker

A source-grounded tracker for ESPR Article 24 disclosure records and Article 25 destruction-ban checks.

Use it to connect product category, discarded quantities, reasons, waste-treatment destination, prevention measures, owners, evidence, and source gaps.

This tracker is for economic operators that discard unsold consumer products directly or have them discarded on their behalf. It keeps the Article 24 annual disclosure record separate from the narrower Article 25 destruction-ban check, so teams do not treat every discarded product as banned or every exempt operator as free of evidence obligations. Timings in this page are source-linked; verify current legal source language before implementation decisions.

## Classify the product and duty before counting it

Start each row by confirming that the item is a consumer product and that it is unsold. ESPR defines unsold consumer products to include surplus stock, excess inventory, deadstock, and consumer returns under withdrawal rights or a longer trader withdrawal period.

Then record the operator status. Article 24 disclosure does not apply to micro and small enterprises, and applies to medium-sized enterprises from 19 July 2030. The tracker should still capture whether an exempt operator is receiving goods from a covered operator, because Article 25 bars circumvention through transfers.

- Product record: product type or category, internal SKU or model family, and consumer-product classification.
- Unsold status: surplus stock, excess inventory, deadstock, withdrawal return, or longer trader-return case.
- Operator record: economic operator name, enterprise-size status, direct discard or discard on behalf, and whether another operator supplied the goods.
- Duty record: Article 24 disclosure in scope, Article 25 ban check required, both, or source gap pending later act review.

Sources for this answer:

- [Regulation (EU) 2024/1781 (ESPR)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Binding ESPR source for the definitions of destruction and unsold consumer product, the Article 24 disclosure trigger, and the enterprise-size carve-outs.
- [European Commission ESPR overview](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en?ref=sorena.io) - Commission overview supporting the public-facing summary that ESPR requires large and eventually medium-sized companies to disclose discarded unsold consumer products on their websites.

## Record the Article 24 disclosure fields

Article 24 names the core disclosure fields. The tracker should collect those fields before publication: annual number and weight, differentiated by product type or category; reasons for discarding; any relevant Article 25 derogation; the proportion delivered to each waste-hierarchy activity; and measures taken or planned to prevent destruction.

Keep source status beside each field. The ESPR regulation is binding for the field list, but the detailed disclosure format and verification rules depend on implementing acts. If the implementing-act text is not available in the grounding set, do not invent a table template, assurance method, or category taxonomy.

- Count fields: reporting year, number discarded, weight discarded, product type or category, unit basis, and inventory source.
- Reason fields: business reason for discard and whether a listed Article 25 derogation is being relied on for a banned product.
- Destination fields: proportion delivered for preparing for reuse, refurbishment, remanufacturing, recycling, other recovery including energy recovery, and disposal.
- Prevention fields: measures already taken and measures planned to prevent destruction of unsold consumer products.
- Source-status field: binding regulation, Commission overview, later implementing/delegated act found, or unresolved source gap.

Sources for this answer:

- [Regulation (EU) 2024/1781 (ESPR)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Article 24 grounds the annual disclosure fields: number and weight by type or category, reasons, derogation where relevant, waste-hierarchy destination, and prevention measures.
- [European Commission news on ESPR adoption](https://commission.europa.eu/news-and-media/news/new-law-make-products-eu-market-more-sustainable-2024-07-19_en?ref=sorena.io) - Commission adoption news summarizes the website disclosure duty as annual information including number, weight, and reasons for discarded products.

## Link the disclosure row to the destruction-ban check

The disclosure duty and the destruction ban are related but not identical. Article 24 can require a website disclosure for discarded unsold consumer products across product sectors, subject to operator-size rules. Article 25 prohibits destruction only for unsold consumer products listed in Annex VII, starting from the regulation's stated application dates.

For each row, add a ban-status column. Annex VII currently lists apparel and clothing accessories and footwear through commodity-code entries. If the product is not in Annex VII, do not mark it as banned unless a grounded later act adds it; instead, mark the ban status as not supported by current grounded sources.

- Ban scope: Annex VII apparel and clothing accessories, Annex VII footwear, not Annex VII, or source gap for later amendments.
- Application status: general Article 25 date, medium-sized enterprise date, micro or small enterprise carve-out, or not determined from grounded sources.
- Anti-circumvention check: record whether an out-of-scope operator received unsold consumer products for destruction from an operator covered by the ban.
- Derogation evidence: record only the Article 25(5) reason category supported by ESPR and the evidence file; do not create national or company-specific exemptions from this tracker.

Sources for this answer:

- [Regulation (EU) 2024/1781 (ESPR)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Article 25 and Annex VII ground the destruction-ban relationship, current product categories, anti-circumvention rule, enterprise-size timing, and listed derogation reasons.
- [European Commission news on ESPR adoption](https://commission.europa.eu/news-and-media/news/new-law-make-products-eu-market-more-sustainable-2024-07-19_en?ref=sorena.io) - Commission adoption news supports the summary that the initial ban concerns unsold textiles and footwear and can be extended to other sectors where evidence shows need.

## Publication, evidence, and owner controls

Article 24 requires clear and visible disclosure at least on an easily accessible website page, annually, covering the preceding financial year. The tracker should therefore keep both the public disclosure evidence and the operational evidence used to calculate it.

Article 24 also requires information and documentation to be provided to the Commission or a competent national authority within 30 days of a request, unless that information is already available to the authority under another legal act. Assign owners who can retrieve the underlying delivery, reception, derogation, and publication evidence without rebuilding the record from memory.

- Publication owner: web or sustainability reporting owner, public URL, publication date, and screenshot or archive evidence.
- Inventory owner: source system for number and weight, product-category mapping, and reporting-year reconciliation.
- Waste and reverse-logistics owner: delivery and reception evidence for preparing for reuse, recycling, other recovery, and disposal destinations.
- Legal or compliance owner: enterprise-size assessment, Article 25 ban status, derogation evidence, authority-request response owner, and source-status review.
- Evidence owner: retained calculation workbook, waste-transfer records, return records, donation or reuse records, public page proof, and unresolved source-gap log.

Sources for this answer:

- [Regulation (EU) 2024/1781 (ESPR)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Article 24 grounds website visibility, annual publication, preceding-financial-year coverage, and the 30-day documentation response requirement.
- [European Commission ESPR overview](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en?ref=sorena.io) - Commission overview supports treating the disclosure as a website publication obligation and identifies adopted later acts as items to verify before finalizing format-specific fields.

*Recommended next step*

*Placement: after evidence section*

## Build an ESPR unsold-goods evidence file

Use this tracker to connect Article 24 publication fields, Article 25 ban checks, evidence owners, and source gaps before publishing discarded-product disclosures.

- [Open Research Copilot](/solutions/research-copilot.md): Answer ESPR implementation questions with cited source material.
- [Discuss ESPR implementation](/contact.md): Review unsold-goods scope, disclosure evidence, and source gaps with Sorena.

## Unresolved source gaps to leave visible

The grounding set supports the regulation-level tracker fields and the Commission's high-level implementation summary. It does not provide enough text to restate the detailed implementing-act disclosure format, verification method, or delegated-act derogation text adopted after ESPR without checking those source documents directly.

Keep those gaps in the tracker as blocked fields instead of filling them with guesses. A blocked source field is better than a false disclosure template, invented product taxonomy, or unsupported national rule.

- Blocked field: final implementing-act disclosure format and verification details, until the implementing act text is added as a grounded source.
- Blocked field: final delegated-act derogation conditions beyond the Article 25(5) reason categories, until the delegated act text is added as a grounded source.
- Blocked field: later additions to Annex VII beyond apparel, clothing accessories, and footwear, unless a grounded delegated act amends the annex.
- Blocked field: Member State penalties, authority forms, filing portals, or national enforcement rules; this tracker only supports the EU-level facts grounded here.

Sources for this answer:

- [Regulation (EU) 2024/1781 (ESPR)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Article 24 requires implementing acts for disclosure details and format; Article 25 requires delegated acts for derogations and future Annex VII amendments.
- [European Commission ESPR overview](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en?ref=sorena.io) - Commission overview indicates that delegated and implementing acts on destruction of unsold consumer products were adopted, but this tracker does not restate their detailed content without grounded act text.

## Primary sources

- [Regulation (EU) 2024/1781 (ESPR)](https://eur-lex.europa.eu/eli/reg/2024/1781/oj/eng?ref=sorena.io) - Binding source for ESPR definitions, Article 23 prevention, Article 24 disclosure fields and publication duty, Article 25 destruction-ban relationship, Annex VII categories, and Article 26 consolidated Commission reporting.
  - Quote: "Disclosure of information on unsold consumer products"
- [European Commission ESPR overview](https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/ecodesign-sustainable-products-regulation_en?ref=sorena.io) - Commission overview supporting the public summary of ESPR unsold-product rules, website disclosure by large and eventually medium-sized companies, and the existence of later delegated and implementing acts to verify.
  - Quote: "Rules to address destruction of unsold consumer products"
- [European Commission news on ESPR adoption](https://commission.europa.eu/news-and-media/news/new-law-make-products-eu-market-more-sustainable-2024-07-19_en?ref=sorena.io) - Commission adoption news supporting the high-level explanation that ESPR bans destruction of unsold textiles and footwear, may extend bans to other sectors if evidence supports them, and requires website disclosure of discarded product information.
  - Quote: "ban the destruction of unsold textiles and footwear"

## Related Topic Guides

- [ESPR and DPP connection: delegated acts, identifiers, and access](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-and-dpp-connection.md): How ESPR connects ecodesign information requirements to Digital Product Passports, including delegated acts, data carriers, identifiers, access rights, registry, and architecture choices.
- [ESPR Applicability Test for Products and DPP Readiness](/artifacts/eu/ecodesign-for-sustainable-products-regulation/applicability-test.md): A source-linked ESPR applicability test for physical product scope, exclusions, delegated-act dependency, economic operator triage, DPP readiness, unsold goods, and evidence.
- [ESPR compliance checklist for delegated acts and DPP readiness](/artifacts/eu/ecodesign-for-sustainable-products-regulation/checklist.md): A source-linked ESPR checklist for monitoring delegated acts, mapping product requirements, preparing technical documentation, and building DPP and unsold-goods evidence.
- [ESPR compliance program operating model](/artifacts/eu/ecodesign-for-sustainable-products-regulation/compliance-program-operating-model.md): Build an ESPR operating model for product-group intake, delegated-act monitoring, supplier evidence, DPP governance, release gates, and authority response.
- [ESPR compliance: delegated acts, DPP and evidence](/artifacts/eu/ecodesign-for-sustainable-products-regulation/compliance.md): Practical ESPR compliance guidance for mapping product delegated acts, Digital Product Passport dependencies, unsold goods duties, technical documentation, standards, and market-surveillance evidence.
- [ESPR deadlines and compliance calendar](/artifacts/eu/ecodesign-for-sustainable-products-regulation/deadlines-and-compliance-calendar.md): Source-linked ESPR calendar for framework dates, delegated-act dependency, working-plan monitoring, unsold-goods disclosure, and DPP readiness limits.
- [ESPR delegated act intake by product group](/artifacts/eu/ecodesign-for-sustainable-products-regulation/delegated-act-intake-by-product-group.md): A grounded intake checklist for tracking ESPR delegated acts by product group, covering product identification, DPP data, ecodesign requirements, conformity evidence, and source limits.
- [ESPR delegated act intake workflow](/artifacts/eu/ecodesign-for-sustainable-products-regulation/delegated-act-intake-workflow.md): A source-grounded intake workflow for ESPR delegated acts: trigger checks, product-group scope, requirement extraction, DPP impacts, release gates, owners, and evidence outputs.
- [ESPR delegated acts FAQ: product rules, DPP impact, and monitoring](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/delegated-acts.md): Standalone FAQ on ESPR delegated acts, why product-group duties depend on them, what teams should monitor, and how they shape Digital Product Passport information.
- [ESPR delegated acts watchlist for product and DPP teams](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-delegated-acts-watchlist.md): Track ESPR delegated-act priorities without inventing dates: product groups, source status, likely requirement types, DPP impact, evidence owners, and open source gaps.
- [ESPR destruction ban and unsold goods FAQ](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/destruction-ban.md): What ESPR says about preventing destruction of unsold consumer products, annual disclosure, the Annex VII apparel and footwear ban, and grounded derogation evidence.
- [ESPR destruction of unsold goods: disclosure, ban scope, and records](/artifacts/eu/ecodesign-for-sustainable-products-regulation/destruction-of-unsold-goods.md): Source-linked ESPR guide to unsold consumer product disclosure, destruction-ban scope, records, derogations, and national enforcement limits.
- [ESPR DPP information mapping workflow](/artifacts/eu/ecodesign-for-sustainable-products-regulation/dpp-information-mapping-workflow.md): Map ESPR delegated-act information requirements into DPP data elements, source systems, access levels, identifiers, carriers, validation evidence, and unresolved design decisions.
- [ESPR durability, repairability, and recyclability evidence](/artifacts/eu/ecodesign-for-sustainable-products-regulation/durability-repairability-and-recyclability-evidence.md): Build ESPR evidence for durability, repairability, and recyclability without inventing product-group tests before the applicable delegated act is known.
- [ESPR Ecodesign Evidence Checklist](/artifacts/eu/ecodesign-for-sustainable-products-regulation/ecodesign-evidence-checklist.md): Checklist for collecting ESPR ecodesign evidence from delegated acts, technical documentation, supplier substantiation, DPP mapping, standards, and market surveillance records.
- [ESPR ecodesign requirement types: performance, information, and DPP links](/artifacts/eu/ecodesign-for-sustainable-products-regulation/ecodesign-requirement-types.md): Source-grounded guide to ESPR ecodesign requirement types, product parameters, delegated-act dependency, DPP links, and evidence implications.
- [ESPR FAQ: scope, delegated acts, DPP, unsold goods](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq.md): Standalone ESPR FAQ answers on product scope, delegated acts, Digital Product Passports, unsold goods, product priorities, standards, surveillance, and source limits.
- [ESPR harmonised standards and common specifications](/artifacts/eu/ecodesign-for-sustainable-products-regulation/standards-and-common-specifications.md): How ESPR uses harmonised standards, common specifications, delegated acts, and DPP standards evidence without inventing product-specific requirements.
- [ESPR Information Requirements to DPP Mapping](/artifacts/eu/ecodesign-for-sustainable-products-regulation/information-requirements-to-dpp-mapping.md): Map ESPR information requirements into Digital Product Passport data classes, source systems, access rules, carrier choices, validation checks, and evidence records.
- [ESPR Information Requirements, Labels, and Disclosure](/artifacts/eu/ecodesign-for-sustainable-products-regulation/information-requirements-labeling-and-disclosure.md): Grounded ESPR guide to delegated-act information requirements, product labels, digital product passport access, data carriers, and unsold-goods disclosure.
- [ESPR market surveillance FAQ: evidence, DPP data, and authority requests](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/market-surveillance.md): Standalone FAQ on ESPR market surveillance: technical documentation, conformity evidence, DPP data, authority response, delegated-act limits, and national penalties.
- [ESPR market surveillance technical documentation checklist](/artifacts/eu/ecodesign-for-sustainable-products-regulation/market-surveillance-technical-documentation.md): Source-grounded ESPR checklist for technical documentation, conformity evidence, DPP records, and responses to market surveillance authority requests.
- [ESPR penalties and fines: Member State rules and evidence](/artifacts/eu/ecodesign-for-sustainable-products-regulation/penalties-and-fines.md): A conservative ESPR penalties guide explaining Article 74, why fine amounts depend on Member State law, and which conformity and market-surveillance evidence matters.
- [ESPR Product Priorities and Delegated Acts Tracker](/artifacts/eu/ecodesign-for-sustainable-products-regulation/product-priorities-and-delegated-acts-tracker.md): Track ESPR priority product groups, source status, delegated-act progress, expected DPP impact, owners, evidence, and source gaps without treating preliminary studies as binding obligations.
- [ESPR product priorities FAQ: working plan and delegated acts](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/product-priorities.md): Standalone FAQ on ESPR product priorities, the Commission working plan, delegated-act dependency, monitoring points, and limits of preliminary source material.
- [ESPR requirements: delegated acts, ecodesign, DPP, and evidence](/artifacts/eu/ecodesign-for-sustainable-products-regulation/requirements.md): ESPR requirements explained as a framework for delegated acts, ecodesign performance and information rules, Digital Product Passports, unsold goods, technical documentation, and market surveillance.
- [ESPR unsold goods disclosure FAQ](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/unsold-goods-disclosure.md): Standalone FAQ on the ESPR Article 24 duty to disclose discarded unsold consumer products, its relationship to the destruction ban, records, and source limits.
- [ESPR vs Batteries Regulation Comparison](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-vs-batteries-regulation.md): Compare ESPR delegated-act planning with the Batteries Regulation product-specific regime, including DPP overlap, battery passport evidence, timing limits, and source boundaries.
- [ESPR vs Ecodesign Directive](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-vs-ecodesign-directive.md): Compare ESPR with the earlier Ecodesign Directive across scope, legal form, delegated acts, DPP requirements, unsold goods, transition rules, and evidence.
- [ESPR vs GPSR: Sustainability vs Product Safety](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-vs-gpsr.md): A source-limited comparison of ESPR sustainability and product-information requirements against GPSR product-safety context, with evidence and DPP reuse limits.
- [ESPR vs PPWR Comparison](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-vs-ppwr.md): Compare ESPR product ecodesign and Digital Product Passport work with the separate PPWR packaging regime, using only source-linked ESPR and packaging-boundary claims.
- [ESPR vs REACH and RoHS Comparison](/artifacts/eu/ecodesign-for-sustainable-products-regulation/espr-vs-reach-and-rohs.md): Compare ESPR ecodesign, sustainability, information, and digital product passport requirements with source-limited REACH and RoHS substance-control context.
- [EU ESPR DPP obligations FAQ](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/dpp-obligations.md): Standalone FAQ on Digital Product Passport obligations under ESPR, covering delegated acts, identifiers, carriers, access rights, data governance, and supplier evidence limits.
- [Timeline for ESPR: practical implementation guide](/artifacts/eu/ecodesign-for-sustainable-products-regulation/timeline.md): Practical ESPR guidance for Timeline, with source-linked decisions, owners, evidence records, and implementation steps.
- [What ESPR is and why it matters](/artifacts/eu/ecodesign-for-sustainable-products-regulation/what-is-espr-and-why-it-matters.md): A grounded explainer of the EU Ecodesign for Sustainable Products Regulation, including scope, delegated acts, DPPs, unsold goods, and enforcement limits.
- [Which products are in scope of the EU ESPR?](/artifacts/eu/ecodesign-for-sustainable-products-regulation/faq/products-in-scope.md): Standalone FAQ on ESPR product scope, excluded products, delegated-act dependency, working-plan monitoring, and the digital product passport link.


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